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European Aviation Safety Agency — Rulemaking Directorate

Notice of Proposed Amendment 2014-04

Applicability Process map

Affected

regulations and decisions:

Commission Regulation (EC)

No 2042/2003: Part-M and Part-145

Concept Paper:

Terms of Reference:

Rulemaking group:

RIA type:

Technical consultation during NPA drafting:

Duration of NPA consultation:

Review group:

Focussed consultation:

Publication date of the Opinion:

Publication date of the Decision:

No

28.11. 2011

Yes

Light No

3 months

Yes

Yes

2017Q1

Upon adoption of

the Opinion by the Commission

Affected stakeholders:

Air Operators/aircraft owners Continuing Airworthiness

Management Organisations (CAMOs) Maintenance Organisations

Competent Authorities

Driver/origin: Level playing field

Reference: — FAA AC 120-16E, Chapter 8 – Maintenance record keeping system

— FAA 20-162 and TGL 41 on RFID devices

— ICAO Annex 6 Chapter I 8.4

TE.RPRO.00034-003 © European Aviation Safety Agency. All rights reserved.

Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/Internet. of 44

Technical records

RMT.0276 (MDM.076) — 7.2.2014

EXECUTIVE SUMMARY

Technical records are the means to assess the airworthiness status of a product and its components.

Incomplete technical records may lead to a wrong assessment with safety risk.

Although there are specific requirements in the rule, the Agency infers from the number of queries

received that the provisions are not clear enough on what should be kept and for how long.

Furthermore, this NPA evaluates the use of new technologies and copies of the continuing

airworthiness records, providing more guidance on the commonly used information technology (IT)

systems. This evaluation is always done taking into account different operations/aircraft, so the less

complex aviation community is not imposed to hold records in the same way that more complex ones

are.

The Agency received a safety recommendation from AAIB which is addressed within this rulemaking

task (ref.: UNKG-2007-091). It recommends that the maintenance and overhaul records must be part

of the log book and retained until the aircraft/engine/propeller/component has been destroyed or

permanently removed from service.

European Aviation Safety Agency NPA 2014-04

Table of contents



Table of contents

1. Procedural information ............................................................................................. 4 1.1. The rule development procedure ............................................................................. 4 1.2. The structure of this NPA and related documents ...................................................... 4 1.3. How to comment on this NPA .................................................................................. 4 1.4. The next steps in the procedure .............................................................................. 4

2. Explanatory Note ...................................................................................................... 5 2.1. Overview of the issues to be addressed .................................................................... 5 2.2. Objectives ............................................................................................................ 5 2.3. Summary of the Regulatory Impact Assessment (RIA) ............................................... 5 2.4. Overview of the proposed amendments ................................................................... 6

3. Proposed amendments ........................................................................................... 10 3.1. Draft Regulation (Draft EASA Opinion) .................................................................... 10

3.1.1. Annex I to Commission Regulation (EC) No 2042/2003 (Part-M) ......................... 10 3.1.2. Annex II to Commission Regulation (EC) No 2042/2003 (Part-145) ..................... 15

3.2. Draft Acceptable Means of Compliance and Guidance Material (Draft EASA Decision) ... 15 3.2.1. Annex I to Decision 2003/19/RM (AMC to Part-M) is amended as follows: ............ 15 3.2.2. Annex II to Decision 2003/19/RM (AMC to Part-145) is amended as follows: ........ 29 3.2.3. Decision 2012/018/R (AMC and GM to Part-CAT) is amended as follows:.............. 30 3.2.4. Decision 2013/021/R (AMC and GM to Part-NCC) is amended as follows: ............. 30 3.2.5. Decision 2013/022/R (AMC and GM to Part-NCO) is amended as follows: ............. 30

4. Regulatory Impact Assessment (RIA) ..................................................................... 31 4.1. Issues to be addressed ......................................................................................... 31

4.1.1. Safety risk assessment .................................................................................. 32 4.1.2. Who is affected? ........................................................................................... 32 4.1.3. How could the issue/problem evolve? .............................................................. 32

4.2. Objectives ........................................................................................................... 33 4.3. Policy options ...................................................................................................... 33

4.3.1. Inconsistency in the use of the terms ‘Life Limited Parts’ and ‘Service Life Limited

Parts’ 33 4.3.2. Different interpretations as to which components require an EASA Form 1 or

equivalent, and which documents are considered equivalent to an EASA Form 1 ................ 33 4.3.3. Different interpretations of the need for ‘back to birth’ traceability ...................... 34 4.3.4. Inconsistency in 145.A.55 of the record-keeping periods and the periods applicable

to the transfer of records ............................................................................................ 34 4.3.5. Lack of guidance on the use of electronic signature ........................................... 34 4.3.6. Lack of guidance on the acceptability of record copies (scanned, photocopy) ........ 35 4.3.7. Lack of guidance on the acceptability of new technology, such as RFID (Radio

Frequency Identification) ............................................................................................ 35 4.3.8. Lack of harmonisation with the FAA requirements in relation to continuing

airworthiness records ................................................................................................. 35 4.3.9. Safety Recommendation ................................................................................ 35

4.4. Analysis of impacts ............................................................................................... 36 4.4.1. Inconsistency in the use of the terms ‘Life Limited Parts’ and ‘Service Life Limited

Parts’ 36 4.4.2. Different interpretations as to which components require an EASA Form 1 or

equivalent, and which documents are considered equivalent to an EASA Form 1 ................ 37 4.4.3. Different interpretations of the need for ‘back to birth’ traceability ...................... 38 4.4.4. Inconsistency in 145.A.55 of the record keeping periods and the periods applicable

to the transfer of records ............................................................................................ 39 4.4.5. Lack of guidance on the use of electronic signature ........................................... 39 4.4.6. Lack of guidance on the acceptability of records copies (scanned, photocopy) ....... 39 4.4.7. Lack of guidance on the acceptability of new technology, such as RFID (Radio

Frequency Identification) ............................................................................................ 40


Table of contents



4.4.8. Lack of harmonisation with the FAA requirements in relation to continuing

airworthiness records ................................................................................................. 41 4.4.9. Safety Recommendation ................................................................................ 41

4.5. Comparison and conclusion ................................................................................... 42 4.5.1. Comparison of options ................................................................................... 42 4.5.2. Safety Recommendation ................................................................................ 43

5. References .............................................................................................................. 44 5.1. Affected regulations .............................................................................................. 44 5.2. Affected CS, AMC and GM ...................................................................................... 44 5.3. Reference documents ........................................................................................... 44


1. Procedural information



1. Procedural information

1.1. The rule development procedure

The European Aviation Safety Agency (hereinafter referred to as the ‘Agency’) developed

this Notice of Proposed Amendment (NPA) in line with Regulation (EC) No 216/20081

(hereinafter referred to as the ‘Basic Regulation’) and the Rulemaking Procedure2.

This rulemaking activity is included in the Agency’s Rulemaking Programme 2014-2017

under RMT.0276 (former task number MDM.076).

The text of this NPA has been developed by the Agency based on the input of the

Rulemaking group RMT.0276 (MDM.076). It is hereby submitted for consultation of all

interested parties3.

The process map on the title page contains the major milestones of this rulemaking

activity to date and provides an outlook of the timescale of the next steps.

1.2. The structure of this NPA and related documents

Chapter 1 of this NPA contains the procedural information related to this task. Chapter 2

(Explanatory Note) explains the core technical content. Chapter 3 contains the proposed

text for the new requirements. Chapter 4 contains the Regulatory Impact Assessment

showing which options were considered and what impacts were identified, thereby

providing the detailed justification for this NPA.

1.3. How to comment on this NPA

Please submit your comments using the automated Comment-Response Tool (CRT)

available at http://hub.easa.europa.eu/crt/4.

The deadline for submission of comments is 7 May 2014.

1.4. The next steps in the procedure

Following the closing of the NPA public consultation period, the Agency will review all

comments and perform a focussed consultation which will consist of a workshop.

The outcome of the NPA public consultation will be reflected in the respective Comment-

Response Document (CRD).

1 Regulation (EC) No 216/2008 of the European Parliament and the Council of 20 February 2008 on common rules in the

field of civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002 and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1), as last amended by Commission Regulation (EU) No 6/2013 of 8 January 2013 (OJ L 4, 9.1.2013, p. 34).

2 The Agency is bound to follow a structured rulemaking process as required by Article 52(1) of the Basic Regulation. Such process has been adopted by the Agency’s Management Board and is referred to as the ‘Rulemaking Procedure’. See Management Board Decision concerning the procedure to be applied by the Agency for the issuing of Opinions, Certification Specifications and Guidance Material (Rulemaking Procedure), EASA MB Decision No 01-2012 of 13 March 2012.

3 In accordance with Article 52 of the Basic Regulation and Articles 5(3) and 6 of the Rulemaking Procedure. 4 In case of technical problems, please contact the CRT webmaster ([email protected]).

http://hub.easa.europa.eu/crt/

mailto:[email protected]


2. Explanatory Note



2. Explanatory Note

2.1. Overview of the issues to be addressed

Proposed by the Industry and the Member States, the need of a rulemaking task was

indeed found adequate to reduce the safety risk identified in relation to the aircraft’s

technical records.

In 2012 the Agency created a rulemaking group with the participation of experienced

members from industry and civil aviation authorities whose task was the development of

this Notice of Proposed Amendment (NPA).

For more detailed analysis of the issues addressed by this proposal, please refer to the RIA

section 4.1. ‘Issues to be addressed’ which are basically:

— Inconsistency in the use of the terms ‘Life Limited Parts’ and ‘Service Life Limited

Parts’;

— Different interpretations as to which components require an EASA Form 1 or

equivalent, and which documents are considered equivalent to an EASA Form 1;

— Different interpretations of the need for ‘back to birth’ traceability;

— Inconsistency in 145.A.55 of the record-keeping periods and the periods applicable to

the transfer of records;

— Lack of guidance on the use of electronic signature;

— Lack of guidance on the acceptability of records copies (scanned, photocopy);

— Lack of guidance on the acceptability of new technology, such as RFID (Radio

Frequency Identification);

— Lack of harmonisation with the FAA requirements in relation to continuing

airworthiness records.

Additionally, EASA intends to address a Safety Recommendation made by the AAIB (ref.:

UNKG-2007-091): ‘It is recommended that the European Aviation Safety Agency (EASA)

amend EASA Part-145 (and Part-M as necessary) to require that maintenance and overhaul

records that are referred to in airframe, engine and propeller log books, and component

record cards, are deemed to be part of that log book or record card and are retained until

the aircraft, engine, propeller or component has been destroyed or permanently removed

from service.’

2.2. Objectives

The overall objectives of the EASA system are defined in Article 2 of the Basic Regulation.

This proposal will contribute to the achievement of the overall objectives by addressing the

issues outlined in Section 4.1.

The specific objectives are to clarify the use of the current rules and to develop relevant

guidance on the use of new technologies for record-keeping in order to achieve safe and

cost-efficient rules.

2.3. Summary of the Regulatory Impact Assessment (RIA)

Chapter 4 contains the Regulatory Impact Assessment showing which options were

considered and what impacts were identified, with the following conclusion:


2. Explanatory Note




Parts’

The option that provides more benefits is the use of terms ‘time controlled

component’ and ‘life limited parts’ and clarify records requirements depending on the

type of component.


equivalent, and which documents are considered equivalent to an EASA Form 1

The option that provides more benefits is ‘Identify when the EASA Form 1 must be

retained’.

— Different interpretations of the need for ‘back to birth’ traceability

To solve this issue the assessment concludes that the term ‘in-service history’ must

be introduced. This term partially incorporates the concept of back to birth

traceability but keeping some records up to a certain extent defining ‘detailed

maintenance records’.

— Inconsistency in 145.A.55 of the record keeping periods and the periods applicable to

the transfer of records

The inconsistency is solved changing the applicable period to transfer of the records

from three to two years.

— Lack of guidance on the acceptability of records copies (scanned, photocopy)

The assessment concludes as the most benefitial option to create additional guidance

to accept records others than in ‘original paper’.


Frequency Identification)

It is not considered beneficial for the purpose of keeping records to change the rule,

so no guidance is added in the case of RFID.

— Safety Recommendation

After assessing the recommendation, it is not considered beneficial to change the

current rule.

2.4. Overview of the proposed amendments

This NPA:

— proposes a new structure of M.A.305,

— introduces new concepts related to components,

— clarifies the existing requirements of technical records related to continuing

airworthiness and maintenance, after assessing the need of each requirement,

— introduces guidance about IT systems and the use of new technologies and copies in

a way that can be tailored to the complexity of the aircraft/organisations,

— eliminates some inconsistencies, and


2. Explanatory Note



— additionally proposes a change in AMC to Part-CAT5.

Some shortcomings of the current structure of M.A.305 have been identified and

improved:

— Current M.A.305 (b) and (d) quote respectively ‘records shall consist of’ and ‘records

shall contain’ while not making clear what the rest of the requirements are, if not

records. This lack of clarity is eliminated by including a single point stating what

records ‘shall contain’ and referring to the corresponding paragraphs.

— Additionally, the requirements for records at aircraft level are mixed with those

records at component level. The proposal separates both requirements.

— Lack of clarity with regard to what to keep when the aircraft or its components, as

appropriate, are permanently withdrawn from service. The proposal makes a

distinction between aircraft/components in service and those permanently withdrawn

from service.

M.A.305 (a) is amended for clarity purposes.

M.A.305 (b) is replaced to indicate what the aircraft continuing airworthiness records

system shall contain, cross-referencing other paragraphs. AMC M.A.305 (b) 1 provides

guidance in the case of engine modular design.

M.A.305 (c) is replaced to include the statuses and reports that are part of the aircraft

continuing airworthiness records. AMC M.A.305 (c) (1), (2) and (3) and GM M.A.305 (c)

(2) are added to explain what each status should include. The following means and

guidance are included related to the modification status:

— it should include components subjected to airworthiness limitations,

— it should be sufficiently detailed to identify any installed field loadable software,

— when a component is replaced by a fully interchangeable alternate component, it is

not considered a modification, and

— guidance material on examples of listings of components.

M.A.305 (d) is replaced to request the statuses specific to components. The terms ‘life

limited part’ and ‘time controlled component’ are introduced while the term ‘service life-

limited component’ is removed from the proposal. The current AMC MA305 (d) and AMC

M.A.305 (d) (4) and AMC M.A.305 (h) points are deleted and the new point GM M.A.305

(d)(2) is added. These points define ‘life limited part’, ‘time controlled component’, ‘current

status’, ‘in-service history record’ and include some guidance on different maintenance

processes (MSG-1, MSG-2 and MSG-3) to avoid confusion.

M.A.305 (e) is replaced to specify the documents and data to be kept and the retention

period. This point is divided into four paragraphs:

— Operator’s technical log system. The current M.A.306 (c) requirement is moved into

this paragraph, so M.A.306 (c) is deleted;

5 Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and

administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council as last amended by Commission Regulation (EU) No 800/2013 of 14 August 2013.


2. Explanatory Note



— General data: specific information on what to keep depending on the requirement at

aircraft level (AD, modifications and repairs and scheduled maintenance or other

maintenance required for continuing airworthiness);

— Data specific to certain components, which introduces the new term ‘in-service

history record’ for life limited parts; and

— Retention periods for data and documents when the aircraft and its components have

been permanently withdrawn from service.

AMC M.A.305 (e) is added to provide means to comply with:

— how the person or organisation responsible for the aircraft continuing airworthiness

can use the system to record the aircraft continuing airworthiness data and the main

features if the system used is IT based (record making),

— the content of logbook/logcard,

— different forms of record keeping (paper, electronically digitised copy, etc.) and the

main characteristics for digitised records,

— the main characteristics of systems used for retention of digitised records, giving the

possibility of disposal of the original paper records when the competent authority has

approved such systems, and

— lost or destroyed records.

AMC M.A.305 (e) (2) is added to provide guidance on what to keep under modifications,

repairs and ADs.

AMC M.A.305 (e) (3) provides means in the case of missing records.

GM M.A.305 (e) (3) is added to clarify that it is not requested to retain EASA Form 1 for

certain components.

A new AMC M.A.305 (f) details the case where the owner/operator arranges for a

maintenance organisation to retain the aircraft continuing airworthiness records.

M.A.305 (g) is amended for clarity.

M.A.305 (h) is deleted.

AMC M.A.305 (h) and AMC M.A.305 (h) (6) are deleted.

A new GM M.A.305 is added to provide the definitions of the terms used through M.A.305.

M.A. 503, M.A.504 (c), AMC M.A.501 (b), AMC M.A.504 (c) and AMC M.A.504 (d) (2) are

amended for consistency.

AMC M.A.613 (a) is amended for consistency.

Point M.A.614 (b) is amended to clarify what the maintenance organisation must transfer

to the owner/operator so that the latter can demonstrate compliance with Part-M

requirements on the ‘detailed maintenance records’.

M.A.710 and Appendix II to M.A.201 (h)1 are amended for consistency.

AMC M.A.710 (a), AMC M.A.901 (d) and (g), AMC M.A.904 (a)(2), AMC M.A.904 (b),

Appendix XI to AMC M.A.708 (c) and Appendix III to GM 1 M.B.303 (b) are amended for

consistency.


2. Explanatory Note



145.A.55 (b) and (c) are amended to clarify what the maintenance organisation must

transfer to the owner/operator so that the latter can demonstrate compliance with Part-M

requirements on the ‘detailed maintenance records’. Additionally Part-145 is amended to

be consistent with the different retention periods of records mentioned in the point.

AMC No2 to 145.A.50 (d) and GM 145.A.55 (a) are amended for consistency.

Points AMC1 CAT.IDE.A.105, AMC1 CAT.IDE.H.105 are added to Part-CAT in order to

provide operators with a means to comply with the responsibility regarding the availability

of the components required for the intended operation that are not controlled for the

purpose of continuing airworthiness management. The same logic applies for the new

points AMC1 NCC.IDE.A.105 and AMC1 NCC.IDE.H.105 to Part-NCC and AMC1

NCO.IDE.A.105 and AMC1 NCO.IDE.H.105 to Part-NCO.


3. Proposed amendments




The text of the amendment is arranged to show deleted text, new or amended text as

shown below:

(a) deleted text is marked with strike through;

(b) new or amended text is highlighted in grey bold;

(c) an ellipsis (…) indicates that the remaining text is unchanged in front of or following

the reflected amendment.

3.1. Draft Regulation (Draft EASA Opinion)

3.1.1. Annex I to Commission Regulation (EC) No 2042/2003 (Part-M)

Point M.A.305(a) is amended as follows:

M.A.305 Aircraft continuing airworthiness record system

(a) At the completion of any maintenance, the certificate of release to service required

by point M.A.801 or point 145.A.50 shall be entered included in the aircraft

continuing airworthiness records. Each entry shall be made as soon as practicable but

in no case more than 30 days after the day of the maintenance action.

Point M.A.305(b) is replaced as follows:


(b) The aircraft continuing airworthiness records shall consist of:

1. an aircraft logbook, engine logbook(s) or engine module log cards, propeller

logbook(s) and log cards, for any service life limited component as appropriate, and

2. when required in point M.A.306 for commercial air transport or by the Member State

for commercial operations other than commercial air transport, the operator’s

technical log.

(b) The aircraft continuing airworthiness records shall contain the following:

1. a record of the date, total in-service life accumulated in flight hours

and/or flight cycles and/or landings and/or any other applicable

parameter, for the aircraft, engine(s) and/or propeller(s) after each

flight;

2. the data described in (c) and (d) together with the supporting detailed

maintenance records described in (e); and

3. when required in point M.A.306 for commercial air transport or by the

Member State for commercial operations other than commercial air

transport, the operator’s technical log.

Point M.A.305(c) is replaced as follows:


(c) The aircraft type and registration mark, the date, together with total flight time and/ or

flight cycles and/or landings, as appropriate, shall be entered in the aircraft logbooks.

(c) The aircraft continuing airworthiness records shall include the current:





1. status of airworthiness directives and measures mandated by the

competent authority in immediate reaction to a safety problem;

2. status of modifications and repairs;

3. status of compliance with the aircraft maintenance programme;

4. mass and balance report; and

5. status of deferred maintenance tasks and deferred defects rectification.

Point M.A.305(d) is replaced as follows:


(d) The aircraft continuing airworthiness records shall contain the current:

1. status of airworthiness directives and measures mandated by the competent

authority in immediate reaction to a safety problem;

2. status of modifications and repairs;

3. status of compliance with maintenance programme;

4. status of service life limited components;

5. mass and balance report;

6. list of deferred maintenance.

(d) The aircraft continuing airworthiness records shall include the following

additional information specific to components:

1. current status of life limited parts including the life accumulated by

each affected part in relation to the applicable airworthiness limitation

parameter; and

2. current status of time controlled components, including the life

accumulated by the affected components in the applicable parameter,

since the last accomplishment of scheduled maintenance specified in

the aircraft maintenance programme.

Point M.A.305(e) is replaced as follows:


(e) In addition to the authorised release document, EASA Form 1 or equivalent, the

following information relevant to any component installed (engine, propeller, engine

module or service life-limited component) shall be entered in the appropriate engine

or propeller logbook, engine module or service life limited component log card:

1. identification of the component; and

2. the type, serial number and registration, as appropriate, of the aircraft, engine,

propeller, engine module or service life-limited component to which the particular

component has been fitted, along with the reference to the installation and removal

of the component; and

3. the date together with the component’s accumulated total flight time and/or flight

cycles and/or landings and/or calendar time, as appropriate; and

4. the current paragraph (d) information applicable to the component.

(e) The owner or operator shall ensure that a system has been established to

keep the following documents and data for the periods specified in a form

acceptable to the competent authority:

1. Operator’s technical log system: the technical log or data equivalent in

scope and detail contained in the information technology system

corresponding to the 36 months prior to the last entry shall be

retained.





2. General data:

(i) the certificate of release to service and detailed maintenance

records demonstrating compliance with airworthiness directives

and measures mandated by the competent authority in immediate

reaction to a safety problem applicable to the aircraft, engine(s),

propeller(s) and components fitted thereto, as appropriate, until

such time as the information contained therein is superseded by

new information equivalent in scope and detail but not less than

24 months;

(ii) the certificate of release to service and detailed maintenance

records demonstrating compliance with the applicable data in

accordance with M.A.304 for current modifications and repairs to

the aircraft, engine(s), propeller(s) and any component subject to

airworthiness limitations; and

(iii) the certificate of release to service and detailed maintenance

records of all scheduled maintenance or other maintenance

required for continuing airworthiness in respect of the aircraft,

engine(s), propeller(s), as appropriate, until such time as the

information contained therein is superseded by new information

equivalent in scope and detail but not less than 24 months;

3. Data specific to certain components:

(i) an in-service history record for each life limited part from which

the current status of compliance with airworthiness limitations

can be determined;

(ii) the certificate of release to service and detailed maintenance

records for the last accomplishment of any scheduled

maintenance, and any subsequent unscheduled maintenance, on

all life limited parts and time controlled components until the

scheduled maintenance has been superseded by another

scheduled maintenance of equivalent scope and detail but not less

than 24 months;

4. Retention periods when the aircraft is permanently withdrawn from

service:

(i) the data required in M.A.305(b)1 in respect of the aircraft,

engine(s), and propeller(s) shall be retained at least 24 months;

(ii) the last effective status and reports identified in M.A.305(c) and

(d) shall be retained for at least 24 months;

(iii) the most recent certificate of release to service and detailed

maintenance records identified in M.A.305(e)2 and (e) 3 shall be

retained for not less than 24 months.

Point M.A.305(g) is amended as follows:


(g) All entries made in the aircraft continuing airworthiness records system shall be

clear and accurate. When it is necessary to correct an entry, the correction shall be

made in a manner that clearly shows the original entry.





Point M.A.305(h) is deleted


(h) An owner or operator shall ensure that a system has been established to keep the

following records for the periods specified:

1. all detailed maintenance records in respect of the aircraft and any service life limited

component fitted thereto, until such time as the information contained therein is

superseded by new information equivalent in scope and detail but not less than 36

months after the aircraft or component has been released to service; and

2. the total time in service (hours, calendar time, cycles and landings) of the aircraft

and all service life-limited components, at least 12 months after the aircraft or

component has been permanently withdrawn from service; and

3. the time in service (hours, calendar time, cycles and landings) as appropriate, since

last scheduled maintenance of the component subjected to a service life limit, at

least until the component scheduled maintenance has been superseded by another

scheduled maintenance of equivalent work scope and detail; and

4. the current status of compliance with maintenance programme such that compliance

with the approved aircraft maintenance programme can be established, at least until

the aircraft or component scheduled maintenance has been superseded by other

scheduled maintenance of equivalent work scope and detail; and

5. the current status of airworthiness directives applicable to the aircraft and

components, at least 12 months after the aircraft or component has been

permanently withdrawn from service; and

6. details of current modifications and repairs to the aircraft, engine(s), propeller(s) and

any other component vital to flight safety, at least 12 months after they have been

permanently withdrawn from service.

Point M.A.306(c) is deleted as follows:

M.A.306 Operator’s technical log system

(c) An operator shall ensure that the aircraft technical log is retained for 36 months after

the date of the last entry.

Point M.A.503 is amended as follows:

M.A.503 Life limited parts and time controlled components Service life limited

components

(a) Installed service life limited life limited parts and time controlled components

shall not exceed the approved service life limit as specified in the approved

maintenance programme and airworthiness directives, except as provided for in point M.A.504(c).

(b) The approved limitservice life is expressed in calendar time, flight hours, landings or cycles, as appropriate.

(c) At the end the approved limit service life, the component must be removed from the

aircraft for maintenance, or for disposal in the case of life limited partscomponents

with a certified life limit.





Point M.A.504(c) is amended as follows:

M.A.504 Control of unserviceable components

(c) Components which have reached their certified mandatory life limit limitation or

contain a non-repairable defect shall be classified as unsalvageable and shall not be

permitted to re-enter the component supply system, unless the certified mandatory

life limits limitation has have been extended or a repair solution has been approved according to M.A.304.


M.A.614 Maintenance records

(b) The approved maintenance organisation shall provide a copy of each certificate of

release to service to the aircraft owner, together with a copy of any specific repair/modification data used for repairs/modifications carried out.

(b) The approved maintenance organisation shall provide a copy of each

certificate of release to service to the aircraft owner, together with a copy of

any detailed maintenance records associated with the work carried out and

necessary to demonstrate compliance with M.A.305.


M.A.710 Airworthiness review

(a) To satisfy the requirement for the airworthiness review of an aircraft referred to in

point M.A.901, a full documented review of the aircraft records shall be carried out by

the approved continuing airworthiness management organisation in order to be

satisfied that:

(…)

7. all service life limited life limited parts and time controlled components

installed on the aircraft are properly identified, registered and have not

exceeded their approved service life limit; and

Appendix II to M.A.201(h)1 is amended as follows:

Appendix II to M.A.201(h)(1): Sub-contracting of continuing airworthiness

management tasks

(…)

2.11 Service life limit Mandatory life limitation or scheduled maintenance controls &

component control/removal forecast.

(…)

2.15 Continuing airworthiness records

These may be maintained and kept by the sub-contracted organisation on behalf of

the operator who remains the owner of these documents. However, the operator

should be provided with the current status of AD compliance and service life limited

life limited parts and time controlled components in accordance with agreed

procedures. The operator should also be provided with unrestricted and timely access

to original records as and when needed. On-line access to the appropriate

information systems is acceptable.





3.1.2. Annex II to Commission Regulation (EC) No 2042/2003 (Part-145)

Point 145.A.55 is amended as follows:

145.A.55 Maintenance records

(b) The organisation shall provide a copy of each certificate of release to service to the

aircraft operator, together with a copy of any specific repair/modification data used for repairs/modifications carried out.

(b) The organisation shall provide a copy of each certificate of release to service

to the aircraft operator, together with a copy of any detailed maintenance

record associated with the work carried out and necessary to demonstrate

compliance with M.A.305.

(c) The organisation shall retain a copy of all detailed maintenance records and any

associated maintenance data for three two years from the date the aircraft or component to which the work relates was released from the organisation.

3.2. Draft Acceptable Means of Compliance and Guidance Material (Draft EASA Decision)

3.2.1. Annex I to Decision 2003/19/RM (AMC to Part-M) is amended as follows:

Point GM M.A.305 is added

GM M.A.305 Aircraft continuing airworthiness record system

(1) ‘Applicable airworthiness limitation parameter’ and ‘applicable parameter’

mean ‘in flight hours’ and/or ‘flight cycles’ and/or ‘landings’ and/or

‘calendar time’, as appropriate.

(2) A ‘life limited part’ is a part for which the maintenance schedule of the

aircraft maintenance programme requires the permanent removal from

service when, or before, the specified mandatory life limitation in the

applicable parameter is reached.

(3) The ‘current status of life limited parts’ should indicate, for each affected

part, the life limitation, total number of accumulated flight hours and/or

flight cycles and/or calendar time and/or life in any other applicable

parameter (as appropriate) and the remaining life in flight hours and/or

flight cycles and/or calendar time and/or any other applicable parameter

before the life limitation is reached.

(4) The term ‘time controlled components’ embraces any component for which

the maintenance schedule of the aircraft maintenance programme requires

periodically the removal for restoration, the replacement, or the quantitative

inspection of component’s performance.

(5) The ‘current status of time controlled components’ means the current status

of compliance with the required periodic maintenance task(s) from the

maintenance schedule of the aircraft maintenance programme specific to the

time controlled components. It should include the life accumulated by the

affected components, the applicable parameter, as appropriate, since the

last accomplishment of scheduled maintenance specified in the maintenance

schedule of the aircraft maintenance programme. Any action that alters the





periodicity of the maintenance task(s) or changes the parameter of this

periodicity should be recorded.

(6) ‘Detailed maintenance records’ are those records required to be kept by the

owner/operator to be able to determine the continuing airworthiness and

configuration of the aircraft in accordance with Part-M relevant for future

maintenance. These are different from the detailed maintenance records

required to be kept by a maintenance organisation as per M.A.614 or

145.A.55(c). Whereas maintenance organisations are required to retain all

detailed records to demonstrate that they worked in compliance with their

respective requirements, aircraft owners/operators need to retain those

records required for assessing the aircraft configuration and the

airworthiness of the aircraft and all components installed. ‘Dirty finger

prints’ may not need to be transferred from the maintenance organisation to

the aircraft owner/operator.

Where the maintenance organisation retains the detailed maintenance

records in accordance with 145.A.55(c) and M.A.614, the owner/operator

should receive the aircraft release to service performed during the

maintenance and necessary to determine the aircraft continuing

airworthiness and its configuration, which includes references to all:

— taskcards,

— modifications,

— airworthiness directives,

— repaired and non-repaired damage, and

— measurements relating to defects.

(7) An airworthiness limitation is a boundary beyond which an aircraft or a

component thereof must not be operated, unless the instruction(s)

associated to this airworthiness limitation is (are) complied with.

(8) ‘Other maintenance required for continuing airworthiness’ means other

maintenance due to abnormal conditions or events with an impact on the

continuing airworthiness of the aircraft at the time of its return to service. It

is not intended to request every single condition described in the

maintenance data, i.e. Aircraft Maintenance Manual chapter 5, but just the

ones that cannot be captured by other means, for example when those are

included in the records for repairs. Some abnormal conditions that could be

kept under this requirement could be lightning strikes, hard landings, long

term storage, propeller or rotor over-speed, over-torque, impact on a main

rotor blade, etc.

(9) The term ‘in-service history records’ embraces records from which the

current status of life limited parts can be determined.

Such records document each time a life limited part is placed in service or

removed from service. They should clearly:

(i) identify the part by its part number and serial number,

(ii) show the date of installation and removal (i.e. date on/date off),

(iii) show the details of the installation and removal (i.e. type, serial

number, weight variant, thrust rating, as appropriate, of the aircraft,

engine, engine module, or propeller) at installation and removal of the

part that are necessary to appropriately control the life limitation.





(iv) show the total in-service life accumulated in flight hours and/or flight

cycles and/or landings and/or calendar time and/or any other

applicable parameter, as appropriate, corresponding to the dates of

installation and removal of the part.

Any other events that would affect the life limitation, such as a modification

(in accordance with airworthiness directives, service bulletins or any

product improvements) that affects the life limitation or changes the

limitation parameter, must also be included in the in-service history record.

Not all modifications would necessarily be pertinent to the life limitation of

the component.

Point AMC M.A.305(b)1 is added as follows:

Some gas turbine engines are assembled from modules and the total life

accumulated in service for the complete engine may not be kept. When owners

and operators wish to take advantage of the modular design, then the total life

accumulated in service for each module, and maintenance records for each

module, should be maintained. The continuing airworthiness records as specified

should be kept with the module and should show compliance with any mandatory

requirements pertaining to that module.

Point AMC M.A.305(c)1 is added as follows:

AMC M.A.305(c)1 Aircraft continuing airworthiness record system

(a) The current status of ADs, and measures mandated by the competent

authority in immediate reaction to a safety problem, should identify the

product/component, the applicable ADs including revision or amendment

numbers and the date on which the status was updated.

If the AD is generally applicable to the aircraft or component type but is not

applicable to the particular aircraft, engine, propeller or component, then

this should be identified with the reason why it is not applicable.

The AD status should include the release to service date on which the AD or

measure was accomplished, and where the AD or measure is controlled by

flight hours and/or flight cycles and/or landings and/or any other

applicable parameter, as appropriate, it should include the corresponding

total life accumulated in service on the date when the AD or measure was

accomplished. For repetitive ADs or measures, only the dates of the last and

next application should be recorded in the current status. The status should

also specify the method of compliance and which part of a multi-part AD or

measure has been accomplished, where a choice is available in the AD or

measure.

When the AD is multi-part or requests assessments of certain inspections,

this information should be shown as well.



(a) Status of current modifications and repairs means a list of modifications and

repairs embodied on the aircraft. It should include the identification of the

aircraft, engine(s) or propeller(s), as appropriate, and when the

modification or repair was accomplished. Where a modification or repair





creates the need for the accomplishment of repetitive maintenance tasks,

the reference to the applicable tasks of the aircraft maintenance programme

should be added. The status should include the reference to the data in

accordance with M.A.304 that provides the accomplishment procedure for

the modification or repair. It should also specify which part of a multi-part

modification or repair has been accomplished and the method of compliance,

where a choice is available in the data.

(b) The data may include:

(1) installation instructions;

(2) mass and balance change data;

(3) maintenance and repair manual supplements;

(4) maintenance programme changes and instructions for continuing

airworthiness; and/or

(5) aircraft flight manual supplements.

(c) The status of modifications should be sufficiently detailed to identify any

installed field loadable software which is used for operating or controlling

the aircraft.

A field loadable software can be loaded without removal of the equipment

from the aircraft or engine. Other types of field loadable software not used

for operating or controlling, as navigational data bases or entertainment

systems, are not considered under this recording requirement.

(d) For the purpose of recording modifications in accordance with the current

paragraph, a component replaced by a fully interchangeable alternate

component is not considered a modification, if this condition is published by

the design approval holder (DAH).

(e) It is not expected to have the status of modifications and repairs per each

component. This status should include engine(s), propeller(s) and

components subjected to airworthiness limitations, and it is not intended

that it should be retained for other components.

Point GM M.A.305(c)2 is added as follows:

GM M.A.305(c)2 Aircraft continuing airworthiness record system

The status of modifications embodied could include:

(a) List of the installed components

(b) List of other modifications not covered by the previous point.

When aircraft require a specific field loadable software configuration to operate

correctly, a specific listing with this information may be necessary too.



(a) The current status of compliance with the aircraft maintenance programme

means the last and next accomplishment data for the scheduled tasks

specified in the aircraft maintenance programme. Accomplishment data

pertinent to the engine, propeller or component should be stated when a

task is controlled at the engine, propeller, or component level.





(b) Where the task is controlled by flight hours and/or flight cycles and/or

landings and/or calendar time and/or any other applicable parameter, the

total in-service life accumulated by the aircraft, engine, propeller or

component (as appropriate) in the suitable parameter(s) should also be

included. For repetitive tasks, only the date of the last and next applications

should be recorded, as well as the terminating action when it is performed.

Point AMC M.A.305(d) is deleted as follows:

The current status of AD should identify the applicable AD including revision or

amendment numbers. Where an AD is generally applicable to the aircraft or

component type but is not applicable to the particular aircraft or component, then

this should be identified. The AD status includes the date when the AD was

accomplished, and where the AD is controlled by flight hours or flight cycles it should

include the aircraft or engine or component total flight hours or cycles, as

appropriate. For repetitive ADs, only the last application should be recorded in the AD

status. The status should also specify which part of a multi-part directive has been

accomplished and the method, where a choice is available in the AD.

The status of current modification and repairs means a list of embodied modification

and repairs together with the substantiating data supporting compliance with the

airworthiness requirements. This can be in the form of a Supplemental Type

Certificate (STC), SB, Structural Repair Manual (SRM) or similar approved document.

The substantiating data may include:

(a) compliance programme; and

(b) master drawing or drawing list, production drawings, and installation instructions;

and

(c) engineering reports (static strength, fatigue, damage tolerance, fault analysis,

etc.); and

(d) ground and flight test programme and results; and

(e) mass and balance change data; and

(f) maintenance and repair manual supplements; and

(g) maintenance programme changes and instructions for continuing airworthiness;

and

(h) aircraft flight manual supplement.

Some gas turbine engines are assembled from modules and a true total time in

service for a total engine is not kept. When owners and operators wish to take

advantage of the modular design, then total time in service and maintenance records

for each module is to be maintained. The continuing airworthiness records as

specified are to be kept with the module and should show compliance with any

mandatory requirements pertaining to that module

Point AMC M.A.305(d)(4) and AMC M.A.305(h) is deleted

AMC M.A.305 (d) (4) and AMC M.A.305 (h) Aircraft continuing airworthiness

record system

The term ‘service life-limited components’ embraces: (i) components subject to a

certified life limit after which the components should be retired, and (ii) components





subject to a service life limit after which the components should undergo

maintenance to restore their serviceability.

The current status of service life-limited aircraft components should indicate:

i. for components subject to a certified life limit: the component life

limitation, total number of hours, accumulated cycles or calendar time and

the number of hours/cycles/time remaining before the required retirement

time of the component is reached;

ii. for components subject to a service life limit: the component service life

limit, the hours, cycles or calendar time since the component has been

restored back to their service life and the remaining service (hours,

cycles, calendar time) life before the components need to undergo

maintenance.

Any action that alters the components’ life limit (certified or service) or

changes the parameter of the life limit (certified or service) should be

recorded.

When the determination of the remaining life requires knowledge of the

different types of aircraft/engine on which the component has previously

been installed, the status of all service-life limited aircraft components

should additionally include a full installation history indicating the number

of hours, cycles or calendar time relevant to each installation on these

different types of aircraft/engine. The indication of the type of

aircraft/engine should be sufficiently detailed with regard to the required

determination of remaining life.

Recommendations from the type certificate holder on the procedures to

record the remaining life may be considered.

Point GM M.A.305(d)(2) is added as follows:

GM M.A.305(d)(2) Aircraft continuing airworthiness record system

The maintenance schedule of the aircraft maintenance programme may require:

(a) the removal of a component for periodic restoration to return the component

to a specified standard (e.g. removal of landing gear for overhaul);

(b) the periodic replacement of a component by a new one when it is not

possible to restore the item to a specific standard of failure resistance (e.g.

discarding of filters, batteries, discharge cartridges of fire extinguishers,

etc.);

(c) a quantitative inspection to confirm periodically that a component meets

specified performance standards (e.g. functional check of aileron hinge

bearings for excessive play, functional check of emergency exit locking

mechanism, etc.). The component is left in service (no further maintenance

action taken) on the condition that it continues to fulfil its intended purpose

within specified performance limits until next scheduled inspection.

Components subject to the above maintenance schedule requirements are

termed ‘time controlled components’.

Note: The maintenance in accordance:

— with (a) and (b) assumes a predictable deterioration of the component: the

overall reliability invariably decreases with age; and

— with (c) assumes a gradual deterioration of the component: failure

resistance can reduce and drop below a defined level.





For aircraft maintenance programmes developed under a primary maintenance

process oriented methodology (e.g. Maintenance Steering Group-1 (MSG-1) or

MSG-2), the term ‘time controlled component’ applies to ‘Hard Time’ components

and ‘On-Condition’ components. Such terms mean:

(1) Hard Time

This is a preventative process in which known deterioration of a component

is limited to an acceptable level by the maintenance actions which are

carried out at periods related to time in service (e.g. calendar time, number

of cycles, number of landings). The prescribed actions return the component

to its original condition.

(2) On-Condition

It is a preventive process in which the component is inspected or tested, at

specified periods, to an appropriate standard in order to determine whether

it can continue in service. The purpose is to remove the component before

its failure in service.

Note: Components which are not time controlled are instead subject to

Condition-Monitoring. These components are permitted to remain in service

without preventive maintenance until a functional failure occurs (i.e. they

are ‘fly-to failure’).

Point AMC M.A.305 (e) is added as follows:

AMC M.A.305(e) Aircraft continuing airworthiness record system

(a) The information that constitutes the aircraft continuing airworthiness

records may be entered in an information technology (IT) system and/or

other documents equivalent in scope and detail.

IT systems acceptable for supporting the aircraft continuing airworthiness

records should:

(1) include functions so that search of data and production of status is

possible;

(2) allow a transfer of the aircraft continuing airworthiness records data

from one system to another using an industry wide/worldwide data

format or allow printing information;

(3) contain safeguards which prevent unauthorised personnel from altering

data; and

(4) ensure the integrity of the data, including traceability of amendments.

(b) ‘Other document equivalent in scope and detail’ could be an aircraft logbook,

engine logbook(s) or engine module log cards, propeller logbook(s) and log

cards for life limited parts and time controlled components.

Any logbook/logcard should contain:

(1) Identification of the product, part or component it refers to;

(2) Type, serial number and registration, as appropriate, of the aircraft,

engine, propeller, engine module, or component to which the particular

component has been fitted, along with the reference to the installation

and removal;

(3) The date and accumulated total flight time and/or flight cycles and/or

landings and/or calendar time, as appropriate; and





(4) Any AD, modification, repair, maintenance or deferred maintenance

tasks applicable.

If fulfilling the applicable requirements, a logbook/log card as described

above could be a means to comply with the current status of life limited

parts and time controlled components and/or the in-service history record

for each life limited part.

(c) Form of record keeping:

Keeping continuing airworthiness records in a form acceptable to the

competent authority normally means in one of the following formats:

(1) as the original form (either paper or via an approved electronically

signed form)

(2) as an electronically digitised copy of the original paper form, or

(3) as a microfilm or scanned copy of the original form, or

(4) as a paper form where the paper record is a printed reproduction of an

original form from either (1), (2) or (3) above.

Where IT systems are used to retain documents and data, it should be

possible to print a paper version of the documents and data kept.

(d) Non-digitised records:

All physical records should remain legible throughout the required retention

period. Physical records on either paper or microfilm systems should use

robust material, which can withstand normal handling, filing and ageing.

They should be stored in a safe way with regard to damage, alteration and

theft.

(e) Digitised Record:

Digitised records may be created from an original paper record or as a

digital electronic original.

When created from an original paper record:

(1) the creation date of the digitised record should be stored with the

digitised record,

(2) it is advisable to create an individual digitised record for each original,

and

(3) if an organisation creates a large number of digitised records, the use

of database technology should ease the future retrieval of the record.

(f) Digitised Record Retention:

Digitised records when created from an original paper record, or as a digital

electronic original, should be stored on a system which is secured and kept

in an environment protected from damage (e.g. fire, flooding, excessive

temperature or accidental erasing). IT systems should have at least one

backup system, which should be updated at least within 24 hours of any

entry in the primary system. Access to both primary and backup systems is

required to be protected against the ability of unauthorised personnel to

alter the database and they should preferably be located remotely from the

main system.

The system used for retention of digitised records must:





1. Ensure the integrity and accuracy of the record (when created from an

original paper record).

2. Ensure that access to the digitised record has safeguards against

alteration of the data.

3. Provide assurance that the data has not been modified after creation.

4. Be capable of retrieval of individual records within a reasonable time

period.

5. Be maintained against technological obsolescence which would prevent

printing, displaying or retrieval of the digitised records.

Computer backup discs, tapes etc., should be stored in a different location

from that containing the current working discs, tapes, etc., and in a safe

environment.

Where the competent authority has approved a system for digitised record

keeping satisfying the above, the original paper record may be permanently

disposed of.

(g) Lost or destroyed records:

Reconstruction of lost or destroyed records can be done by reference to

other records which reflect the time in service, research of records

maintained by maintenance organisations and reference to records

maintained by individual mechanics, etc. When reconstruction has been

done and the record is still incomplete, the owner/operator may make a

statement in the new record describing the loss and establishing the time in

service based on the research and the best estimate of time in service. The

reconstructed records should be submitted to the competent authority for

acceptance. The competent authority may require the performance of

additional maintenance if not satisfied with the reconstructed records.

Point AMC M.A.305(e)(2) is added as follows:

AMC M.A.305(e)(2) Aircraft continuing airworthiness record system

(1) EASA Form 1 and the Certificate of Conformity of the components used to

perform a modification/repair are not part of the substantiation data for a

modification/repair, which are retained by the maintenance organisation.

(2) In the case of an AD with several steps or with interim assessments during

its application, these intermediate steps are part of the detailed

maintenance records.

Point AMC M.A.305(e)(3) is added as follows:

AMC M.A.305 (e)(3) Aircraft continuing airworthiness record system

(1) An EASA Form 1 and detailed maintenance records are not meant to support

every installation/removal shown in the in-service history records.

(2) Conservative methods to manage missing historical periods are acceptable

to establish the current status of the life limited part. In case of use of a

conservative method, the supporting documents should be endorsed.

Recommendations from the DAH on the procedures to record or reconstruct

the in-service history should be considered.





Point GM M.A.305(e)(3) is added as follows:

GM M.A.305(e)(3) Aircraft continuing airworthiness record system

The EASA Form 1 or equivalent is not requested to be kept for ‘condition

monitoring’ components unless this is the means to fulfil another requirement

quoted in M.A.305, (e.g. maintenance programme task compliance).

Point AMC M.A.305(f) is added as follows:

AMC M.A.305(f) Aircraft continuing airworthiness record system

When an owner/operator arranges for the relevant maintenance organisation to

retain copies of the continuing airworthiness records on its behalf, the

owner/operator will continue to be responsible for the retention of records. If

they cease to be the owner/operator of the aircraft, they also remain responsible

for transferring the records to the new owner/operator of the aircraft.

Point AMC M.A.305(h) is deleted

AMC M.A.305(h) Aircraft continuing airworthiness record system

When an owner/CAMO arranges for the relevant maintenance organisation to retain copies

of the continuing airworthiness records on their behalf, the owner/CAMO will continue to be

responsible for the retention of records. If they cease to be the owner/CAMO of the

aircraft, they also remain responsible for transferring the records to any other person who

becomes the owner/CAMO of the aircraft.

Keeping continuing airworthiness records in a form acceptable to the competent authority

normally means in paper form or on a computer database or a combination of both

methods. Records stored in microfilm or optical disc form are also acceptable. All records

should remain legible throughout the required retention period.

Paper systems should use robust material, which can withstand normal handling and filing.

Computer systems should have at least one backup system, which should be updated at

least within 24 hours of any maintenance. Each terminal is required to contain programme

safeguards against the ability of unauthorised personnel to alter the database.

Continuing airworthiness records should be stored in a safe way with regard to damage,

alteration and theft. Computer backup discs, tapes etc., should be stored in a different

location from that containing the current working discs, tapes, etc., and in a safe

environment. Reconstruction of lost or destroyed records can be done by reference to

other records which reflect the time in service, research of records maintained by repair

facilities and reference to records maintained by individual mechanics, etc. When these

things have been done and the record is still incomplete, the owner/CAMO may make a

statement in the new record describing the loss and establishing the time in service based

on the research and the best estimate of time in service. The reconstructed records should

be submitted to the competent authority for acceptance. The competent authority may

require the performance of additional maintenance if not satisfied with the reconstructed

records.

Point AMC M.A.305(h)(6) is deleted

AMC M.A.305(h)6- Aircraft continuing airworthiness record system

For the purpose of this paragraph, a ‘component vital to flight safety’ means a component

that includes certified life limited parts or is subject to airworthiness limitations or a major

component such as, undercarriage or flight controls.





Point AMC M.A.501(b) is modified as follows:

AMC M.A.501(b) Installation

(3) The person referred to under M.A.801 or the M.A. Subpart F or Part-145 approved

maintenance organisation should be satisfied that the component in question meets

the approved data/ standard, such as the required design and modification

standards. This may be accomplished by reference to the (S)TC holder or

manufacturer’s parts catalogue or other approved data (i.e. Service Bulletin). Care

should also be taken in ensuring compliance with applicable AD and the status of any

service life-limited life limited parts and time controlled components fitted to the

aircraft component.

Point AMC M.A.504(c) is amended as follows:

AMC M.A.504(c) Control of unserviceable components – unsalvageable

components

1. The following types of components should typically be classified as unsalvageable:

(…)

(d) certified life-limited parts life limited parts that have reached or exceeded

their certified life limits specified mandatory life, or have missing or

incomplete records;

Point AMC M.A.504(d)(2) is amended as follows:

AMC M.A.504(d)(2) Control of unserviceable components

4. Since manufacturers producing approved aircraft components should maintain

records of serial numbers for ‘retired’ life limited parts certified life-limited or other

critical components, the organisation that mutilates a component should provide the

original manufacturer with the data plate and/or serial number and final disposition

of the component.

Point AMC M.A.613(a) is modified as follows:

AMC M.A.613(a) Component certificate of release to service

2.4. An EASA Form 1 issued in accordance with this paragraph 2 should be issued by

signing in block 14b and stating ‘Inspected’ in block 11. In addition, block 12 should

specify:

(…)

2.4.4. detail of life used for service life-limited life limited parts and time controlled

components being any combination of fatigue, overhaul or storage life;

2.6.Used aircraft components removed from a serviceable aircraft.

(…)

(g) The flight hours/cycles/landings as applicable of any service life-limited life

limited parts and time controlled components including time since overhaul

should be established.

2.8. Used aircraft components maintained by organisations not approved in accordance

with M.A Subpart F or Part-145.

(…)

(b) replacing of all service life-limited components life limited parts and time

controlled components when no satisfactory evidence of life used is available

and/or the components are in an unsatisfactory condition,





Point AMC M.A.710(a) is modified as follows:

AMC M.A.710(a) Airworthiness review

(1) A full documented review is a check of at least the following categories of

documents:

- list of service life-limited component life limited parts and time controlled

components

Points AMC M.A.901(d) and (g) are amended as follows:

AMC M.A.901(d) and (g) Aircraft airworthiness review

(g) Statement

(…)

- component service life limitations, and;

Point AMC M.A.904(a)(2) is amended as follows:

AMC M.A.904(a)(2) Airworthiness reviews of aircraft imported into the EU

2. In determining the work to be undertaken during the airworthiness review on the

aircraft, the following should be taken into consideration:

(…)

(d) the aircraft continuing airworthiness status such as the aircraft and component

AD status, the SB status, the maintenance status, the status of life limited

parts and time controlled components all service life limited components,

weight and centre of gravity schedule including equipment list;

Point AMC M.A.904(b) is amended as follows:

AMC M.A.904(b) Airworthiness review of aircraft imported into the EU

(c) Documents accompanying the recommendation

(…)

- status of all service life-limited components life limited parts and time controlled

components, and;

Point 2.11 of Appendix XI to AMC M.A.708(c) is modified as follows:

Appendix XI to AMC M.A.708(c) Contracted maintenance

2.11 Service life-limited components Life limited parts and time controlled

components

Life limited parts and time controlled components Service life-limited components

control is the responsibility of the operator.

The Part 145 approved organisation will have to provide the operator with all the necessary

information about the life limited parts and time controlled components service life-

limited components removal/installation so that the operator may update its records (see

also paragraph 2.22 ‘Exchange of information’).





Appendix III to GM1 M.B.303(b) is amended as follows:

Appendix III to GM1 M.B.303(b) ‘KEY RISK ELEMENTS’

C.2 Component control The component control should consider a twofold objective for components

maintenance:

- maintenance for which compliance is mandatory.

- maintenance for which compliance is recommended.

Supporting information Typical inspection items

Depending on each maintenance task, accomplishment is scheduled or unscheduled. Refer to KRE C.1 ‘Aircraft Maintenance Programme’.

Components affected by scheduled maintenance are of two types:

Life-limited components are of two types:

- components subject to a certified life limit;

- components subject to a service life limit.

a) Components with a certified life-limit must be permanently removed from service when, or before, their operating limitation is exceeded. The life limitation is controlled at the component level (in opposition to aircraft level).

b) Components which are subject to a service life (‘time

controlled components’) include the following:

- components for which removal and restoration are scheduled, regardless of their level of failure resistance. Reference is made to hard time components: They are subject to periodic maintenance dealing with a deterioration that is assumed to be predictable (the overall reliability

invariably decreases with age): Failure is less likely to occur before restoration is necessary;

- components for which failure resistance can reduce and drop below a defined level: Inspections are scheduled to detect potential failures. Reference is made to ‘On-condition’

components: They are called such because components, which are inspected, are left in service (no further

1. Check that the mandatory maintenance tasks are identified as such and managed separately from recommendations.

2. Sample check installed components (PN and SN) against aircraft records:

a. Correct Part Number and Serial Number installed.

b. Correct authorised release document available.

3. Check the current status of time-controlled components, with due consideration to deferred items. They must identify:

a. The affected components (Part Number and Serial Number).

b. For components subject to a repetitive task: the task description and reference, the applicable threshold/interval, the last accomplishment data (date, the component’s total accumulated life in Hours, Cycles, Landings, Calendar time, as necessary) and the next planned accomplishment data.

c. For components subject to an unscheduled task: the task description and reference, the accomplishment data (date, the component’s total accumulated

life in Hours, Cycles, Landings, Calendar time, as necessary). Pay attention to ETOPS and CDCCL components.

4. Check current status of life limited parts life-limited components. This status can be requested upon each transfer throughout the operating life of the part:

a. The life limitation, the component’s total accumulated life, and the life remaining before the component’s life limitation is reached (indicating Hours,

Cycles, Landings, Calendar time, as necessary).

b. If relevant for the determination of the remaining life, a full installation history indicating the number of hours, cycles or calendar time relevant to each installation on these different types of aircraft/engine.

5. Check if the aircraft maintenance programme and reliability programme results





maintenance action taken) on the condition that they continue to meet specified performance standards.

Notes:

1. Restoration tasks for hard time components are not the same as ‘On-condition’ tasks, since they do not monitor gradual deterioration, but are primarily done to ensure the item may continue to remain in service until the next

planned restoration.

2. Components subject to ‘condition-monitoring’ are permitted to remain in service without preventive maintenance until functional failure occurs. Reference is made to ‘fly-to-failure’. Such components are subject to unscheduled tasks.

impact the component control.

6. Check that life-limited and time controlled components are correctly marked during a physical survey.

Reference documents: EASA - EASA Part 21.A.805

- EASA Part M.A.302

- EASA Part M.A.305

- EASA Part M.A.501

- EASA Part M.A.503

- EASA Part M.A.710


4. Regulatory Impact Assessment (RIA)



3.2.2. Annex II to Decision 2003/19/RM (AMC to Part-145) is amended as

follows:

AMC No 2 to 145.A.50(d) is amended as follows:

AMC No 2 to 145.A.50(d) Certification of maintenance

2. In the case of the issue of EASA Form 1 for components in storage before Part-145 and

Part-21 became effective and not released on an EASA Form 1 or equivalent in accordance

with 145.A.42(a) or removed serviceable from a serviceable aircraft or an aircraft which

has been withdrawn from service the following applies:

(…)

2.4.4. Detail of life used for service life-limited parts life limited parts and time

controlled components being any combination of fatigue, overhaul or

storage life.

(…)

2.6.1 Serviceable aircraft components removed from a Member State registered

aircraft may be issued with an EASA Form 1 by an appropriately rated

organisation subject to compliance with this subparagraph.

(…)

(g) The flight hours/cycles/landings as applicable of any service life-limited

parts life limited parts and time controlled components including time

since overhaul should be established.

(…)

2.8. Used aircraft components maintained by organisations not approved in accordance

with Part-145. For used components maintained by a maintenance organisation not

approved under Part-145, due care should be taken before acceptance of such

components. In such cases an appropriately rated maintenance organisation approved

under Part-145 should establish satisfactory conditions by:

(…)

(b) replacing all service life-limit components life limited parts and time controlled

components when no satisfactory evidence of life used is available and/or the

components are in an unsatisfactory condition;

Point GM 145.A.55 (a) is amended as follows:

GM 145.A.55(a) Maintenance records

1. Properly executed and retained records provide owners, operators and maintenance

personnel with information essential in controlling unscheduled and scheduled

maintenance, and trouble shooting to eliminate the need for re-inspection and rework to

establish airworthiness.

The prime objective is to have secure and easily retrievable records with comprehensive

and legible contents. The aircraft record should contain basic details of all serialised

aircraft components and all other significant aircraft components installed during the

maintenance performed, to ensure traceability to such installed aircraft component

documentation and associated maintenance data as specified in 145.A.45.





3.2.3. Decision 2012/018/R (AMC and GM to Part-CAT) is amended as follows:

Point AMC1 CAT.IDE.A.105 is added as follows:

AMC CAT.IDE.A.105 Minimum equipment for flight

The operator should control and retain the status of the instruments, equipment or

functions required for the intended operation, such as but not limited to equipment

related to navigation approvals as FM immunity or certain software versions, that

are not controlled for the purpose of continuing airworthiness management.

Point AMC1 CAT.IDE.H.105 is added as follows:

AMC CAT.IDE.H.105 Minimum equipment for flight





3.2.4. Decision 2013/021/R (AMC and GM to Part-NCC) is amended as follows:

Point AMC1 NCC.IDE.A.105 is added as follows:

AMC NCC.IDE.A.105 Minimum equipment for flight





Point AMC1 NCC.IDE.H.105 is added as follows:

AMC NCC.IDE.H.105 Minimum equipment for flight





3.2.5. Decision 2013/022/R (AMC and GM to Part-NCO) is amended as follows:

Point AMC1 NCO.IDE.A.105 is added as follows:

AMC NCO.IDE.A.105 Minimum equipment for flight





Point AMC1 NCO.IDE.H.105 is added as follows:

AMC NCO.IDE.H.105 Minimum equipment for flight










4.1. Issues to be addressed

Technical records are the means to assess the airworthiness status of a product and its

installed components. Incomplete technical records may lead to a wrong assessment with

a safety risk. The economic impact of the recertification of a component is another aspect

of the issue.

Although from the owner/operator point of view there are specific paragraphs in Part-M

dealing with this subject, one of the largest group of questions received by the Agency

from the stakeholders and competent authorities are about continuing airworthiness

records, including their connection with the maintenance records. The main concerns relate

to the wrong understanding of the provisions on what should be kept to be able to assess

the airworthiness status of an aircraft and its installed components, and for how long.

This task will consider the introduction and impact of new technologies (paperless

operation) and copies of the records (scanned,…). Although Information Tool (IT) systems

are commonly used in certain organisations, there is a lack of guidance on their use. It is

important to highlight that the Acceptable Means of Compliance (AMC) give several ways

to comply with the intent of the rule to allow a tailor-made record keeping system

depending on the needs of different aviation communities.

Furthermore, the safety recommendation made by the AAIB from UK (ref.:UNKG-2007-

091) is addressed to retain maintenance records until the aircraft/engine/propeller or

component has been permanently removed from service.

This NPA amends Commission Regulation (EC) 2042/20036 and Decision 2003/19/RM7 of

the Executive Director of the Agency. Some records, which are not related to continuing

airworthiness but to the operation of the aircraft, were not clearly stated in the current

regulation, so it was considered adequate to propose an amendment to the Decision

2012/018/R8 of the Executive Director of the Agency (AMC and GM to Part-CAT).

Additionally the discussion led to a proposal for an amendment to Annex IV ‘Essential

requirements for air operations’ to the Basic Regulation. It is proposed to remove ‘When

the aircraft is leased, all records demonstrating the airworthiness of the aircraft must be

kept at least for the length of the lease.’. This proposal should be evaluated when dealing

with the next amendment to the Basic Regulation.

Feedback received from Industry and NAAs shows the following issues:


Parts’;


equivalent, and which documents are considered equivalent to an EASA Form 1;

6 Commission Regulation (EC) No 2042/2003 of 20 November 2003 on the continuing airworthiness of aircraft and

aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these tasks (OJ L 315, 28.11.2003, p. 1)

7 Decision 2003/19/RM of the Executive Director of the Agency of 28 November 2003 on acceptable means of compliance and guidance material to Commission Regulation (EC) No 2042/2003 of 20 November 2003 on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these tasks.

8 Decision 2012/18/R of 24 October 2012 on acceptable means of compliance and guidance material to Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) 216/2008 of the European Parliament and of the Council — Acceptable Means of Compliance and Guidance Material to Part-CAT





— Different interpretations of the need for ‘back to birth’ traceability;

— Inconsistency in 145.A.55 of the record-keeping periods and the periods applicable to

the transfer of records;

— Lack of guidance on the use of electronic signature;

— Lack of guidance on the acceptability of records copies (scanned, photocopy);


Frequency Identification);

— Lack of harmonisation with the FAA requirements in relation to continuing

airworthiness records.

Additionally, the Agency intends to address a Safety Recommendation made by the UK (ref

UNKG-2007-091): ‘It is recommended that the European Aviation Safety Agency (EASA)

amend EASA Part-145 (and Part-M as necessary) to require that maintenance and overhaul

records that are referred to in airframe, engine and propeller log books, and component

record cards, are deemed to be part of that log book or record card and are retained until

the aircraft, engine, propeller or component has been destroyed or permanently removed

from service.’

4.1.1. Safety risk assessment

Safety risks

In the worst case scenario, the presence of components with unknown airworthiness

status and history may be a contributing factor to or cause of a fatal accident with large

aircraft. Thus, the severity is estimated as catastrophic. Taking into account the absence

of known accidents attributed to this cause, the probability of occurrence is estimated to

be low.

The safety risk associated with the use of the information technology systems should be

addressed.

Additionally, the Agency intends to address a Safety Recommendation made by the AAIB

(ref.: UNKG-2007-091): ‘It is recommended that the European Aviation Safety Agency

(EASA) amend EASA Part-145 (and Part-M as necessary) to require that maintenance and

overhaul records that are referred to in airframe, engine and propeller log books, and

component record cards, are deemed to be part of that log book or record card and are

retained until the aircraft, engine, propeller or component has been destroyed or

permanently removed from service.’

4.1.2. Who is affected?

Owners, operators, maintenance organisations and independent certifying staff are

affected by the future rule as well as competent authorities.

4.1.3. How could the issue/problem evolve?

First of all, if the rule does not change, then the safety risks already identified will not be

addressed. Additionally, paperless operation is already in use and, although the current

regulation does not prevent this (there are some industry segments already using this),

more guidance should be provided, as in the use of information technology and records

copies, in order to ensure that related risks are mitigated.





4.2. Objectives

The overall objectives of the EASA system are defined in Article 2 of the Basic Regulation.

This proposal will contribute to the achievement of the overall objectives by addressing the

issues outlined in Section 4.1.

The specific objectives are to clarify the use of the current rules and to develop relevant

quidance on the use of new technologies for record-keeping in order to achieve safe and

cost-efficient rules.

4.3. Policy options

4.3.1. Inconsistency in the use of the terms ‘Life Limited Parts’ and ‘Service Life

Limited Parts’

Option 1. The term ‘service life-limited component’ is used for components maintained

according to requirements of different natures, which creates confusion. It could be better

explained, as well as ‘life limited parts’.

Option 2. Use of the term ‘critical component’.

Option 3. Use of the term ‘life limited part’ (LLP), which is well known by the industry and

currently used in Part-M and in ICAO. Due to the lack of clarity in the term ‘service life-

limited component’ (see option 1), this term could be deleted. In any case, the records

requirements should not be the same for all the components but depending on certain

characteristics. A set of requirements could be for LLP and other set for components which

are not LLP, but are affected by some maintenance in accordance with the instructions

provided by the Design Approval Holder (DAH). The term ‘time controlled component’

could be used to create another group of components with special characteristics in

accordance with the certification process. A definition of this term could be included in the

AMC using maintenance terminology.

Option No

Short title Description

0 Baseline option (no change in rules; risks remain as outlined in the issue analysis).

1 Clarify current terms under AMC

2 Use of the term ‘critical component’

3 Use of the terms ‘time controlled component’ and ‘life limited parts’

and clarify records requirements depending on the type of component.

4.3.2. Different interpretations as to which components require an EASA Form 1

or equivalent, and which documents are considered equivalent to an EASA

Form 1

Option 1. The intent of the current rulemaking task is to clarify for which components it is

needed to retain EASA Form 1 to assess its airworthiness status. The current regulation is

clear enough about what is equivalent to an EASA Form 1. Additionally, the Agency

initiated rulemaking tasks RMT.0018 and RMT.0571 ‘Installation of parts and appliances

that are released without an EASA Form 1 or equivalent’. On the other hand, it should be

clearly stated when an EASA Form 1 must be retained.





If an ‘equivalent’ to an EASA Form 1 is understood as using new technologies different

from the ones already addressed in the AMC to Appendix II to Part-M, then this option

should be checked in 4.3.5. and 4.3.6.

Option

No


0 Baseline option (no change in rules; risks remain as outlined in the

issue analysis).

1 Clarify when the EASA Form 1 must be retained

4.3.3. Different interpretations of the need for ‘back to birth’ traceability

Option 1. The term ‘back to birth’ traceability could be introduced supporting every step of

the utilization of the component since it was manufactured. Every step of this utilization

should be supported with the corresponding information as a mean to assess the

airworthiness status of the component.

Option 2. Introduce the term ‘in-service history’ which partially incorporates the concept of

back to birth traceability but keeping some records up to a certain extent. An important

issue is ‘detailed maintenance records’ to support such history, not keeping this history

from ‘the birth’ of the component, but from certain time.

Option No


0 Baseline option (no change in rules; risks remain as outlined in the

issue analysis).

1 Introduce the term ‘back to birth traceability’ requesting to keep every single document related to the part since manufacture.

2 Introduce the term ‘in-service history’ which partially incorporates the concept of back to birth traceability but keeping some records up to a certain extent and definition of ‘detailed maintenance records’.

4.3.4. Inconsistency in 145.A.55 of the record-keeping periods and the periods

applicable to the transfer of records

Option 1. The current inconsistency in 145.A.55 of the record-keeping periods and the

periods applicable to the transfer of records is considered an administive error. The

periods should be consistent.

Option No



1 Change the applicable period to retain records from three to two years

4.3.5. Lack of guidance on the use of electronic signature

The electronic signature is described in Directive 1999/93/EC of the European Parliament

and of the Council of 13 December 1999 on a Community framework for electronic





signatures. The records using this type of signature are addressed in the next point, so this

option is merged with the next issue.

4.3.6. Lack of guidance on the acceptability of record copies (scanned,

photocopy)

Option 1. More guidance to accept other forms of records different from the traditional

ones, paper or microfilm.

Option No



1 Additional guidance to accept records others than in ‘original paper’

4.3.7. Lack of guidance on the acceptability of new technology, such as RFID

(Radio Frequency Identification)

Option 1. More guidance to accept the RFID as other means to keep records.

Option No



1 Introduce guidance accepting RFID as part of records


airworthiness records

There are some differences between the FAA and EASA systems, but this topic is covered

by the bilateral agreement, so no action is expected by this rulemaking task.

4.3.9. Safety Recommendation

Option 1. Change in the rule to require that the maintenance and overhaul records are part

of the aircraft log book or component record card, and it must be retained until it is

completely removed from service.

Option

No



1 Change in the rule to require the maintenance organisation to send the

owner/operator the maintenance records to be part of the log book/record card and retain those records until it is completely removed from service.





4.4. Analysis of impacts

4.4.1. Inconsistency in the use of the terms ‘Life Limited Parts’ and ‘Service Life

Limited Parts’

1. Safety impact

Option 0. No change compared with the current situation, with the safety issues

already described in 4.1.(0)

Option 1. The current terms are better described. Possible swapping in requirements

still possible as ‘service life limited components’ is a no clear term.(1)

Option 2. From the safety perspective, defining the need of records depending on the

criticality of a component is a sensible way of addressing the issue. But ‘critical

components’ are not always defined by the DAH, which could create some

uncertainty. (3)

Option 3. The term ‘life limited part’ and the term ‘time controlled component’ are

used, providing a clearer understanding of different components with different

records requirements and depending on information provided by the DAH. (3)

2. Environmental impact

No impact is foreseen for the different options.

3. Social impact

No impact is expected for the different options.

4. Economic impact

Option 0. No change of the current situation. (0)

Options 1 and 3. Cost of recertification of a part because of missing records could be

lower if the requirements are better explained. (1)

Option 2. As a first step, the DAH would have to define ‘critical components’ (-1)

5. General aviation and Proportionality issues


6. Impact on ‘Better Regulation’ and harmonisation

Options 0, 1 and 2. No change compared with the current situation, with the safety

issues already described.(0)

Option 3. Provides more harmonisation using terms already used in other regulatory

systems. (1)





Options Safety Environmental Social Economic GA9 Harmonisation Total

0 - Baseline 0 0 0 0 0 0 0

1 – Clarify

current terms

1 0 0 1 0 0 2

2 – Use ‘critical

component’

3 0 0 -1 0 0 2

3 – Use ‘time

controlled

component’

and ‘life limited

parts’

3 0 0 1 0 1 5

4.4.2. Different interpretations as to which components require an EASA Form 1

or equivalent, and which documents are considered equivalent to an EASA

Form 1

1. Safety impact


already described.(0)

Option 1. The requirement is better explained so the safety risk should be less than

not doing anything.(1)



3. Social impact


4. Economic impact


Options 1. Cost of recertification of a part because of missing records are lower as

the requirements are better explained. (1)


General aviation sector will not be affected by these options.


Options 0, 1 and 2. No change compared with the current situation, with the safety

issues already described.(0)

Option 1. Clarify when an EASA Form 1 is to be retained. (1)

Options Safety Environmental Social Economic GA Harmonisation Total

0 – Baseline 0 0 0 0 0 0 0

1 – Clarify when

EASA Form 1

must be retained

1 0 0 1 0 1 3

9 General aviation and Proportionality issues





4.4.3. Different interpretations of the need for ‘back to birth’ traceability

1. Safety impact


already described. (0)

Option 1. All the documents related to the ‘life’ of the part are kept, even if they are

already overridden by a repeated maintenance action. Therefore, some safety

improvement is foreseen but not proportional to the need to assess the

airworthiness. Furthermore, it could create some confusion as regards the ‘birth’ of

the component and the ‘traceability’ as every single document to support the ‘life’ of

the component. (1)

Option 2. The complete history, called ‘in-service history’, is kept but only some

documents are requested to support that history. The term ‘detailed maintenance

records’ is already used in different contexts (Part-M, Part-145) and means

something different depending on the context, so a better definition would reduce the

safety risk. (3)



3. Social impact


4. Economic impact


Options 1. The parts without the complete history and traceability from ‘birth’ would

have to be recertified with the cost associated, and sometimes without any added

value. (-3)

Option 2. Some parts with missing history or detailed maintenance records would

need to be recertified, but it is less probable than the previous option. In any case,

the records of repairs and modifications of life limited components are already

requested in the current regulation. (-1)


General aviation sector will not be negatively affected by these options if some

guidance is provided to use the log cards as ‘in-service history’. So this requirement

would not be new.


Option 0. The current regulation requests a close concept to ‘in-service history’ under

M.A.305(e), but the AMC explained that it is not needed to record every

removal/installation, just the actions that are affecting the service-life of the

component. This is not aligned with ICAO. (-1)

Option 1. This option would be closer to ICAO than the current regulation, but still

not aligned. (0)

Option 2. The term ‘in-service history’ is used for ICAO so this option offers more

harmonisation. (1)


0 – Baseline 0 0 0 0 0 -1 -1

1 – Introduce

‘back to birth

1 0 0 -3 0 0 -2





traceability’

2 – Introduce

‘in-service

history’

3 0 0 -1 0 1 3

4.4.4. Inconsistency in 145.A.55 of the record keeping periods and the periods

applicable to the transfer of records

1. Safety impact




3. Social impact


4. Economic impact





Options 0. No change compared with the current situation.(0)

Option 1. Provides a ‘better regulation’ removing the inconsistency. (1)


0 – Baseline 0 0 0 0 0 0 0

1 – Change

retain period

from 3 to 2

years

0 0 0 0 0 1 1

4.4.5. Lack of guidance on the use of electronic signature

As already mentioned, merged with the following item.

4.4.6. Lack of guidance on the acceptability of records copies (scanned,

photocopy)

1. Safety impact

Options 0. No change compared with the current situation. Some common used

systems are not even mentioned in the rule, which could create some

misunderstanding regarding the minimum features to request to avoid a safety

impact. (-1)

Option 1. The new guidance would provide guidance with the minimum requirements

to not impact the records kept to assess the airworthiness. (1)






Options 0. No change compared with the current situation. (0)

Option 1. Digital records would be more environmental friendly (1)

3. Social impact


4. Economic impact


Option 1. Digital records would impact in the volume of the records, reducing the

need of room. (1)



Option 1. Some proportionality measures should be provided not to impose the same

system to all the aviation community but proportional to their needs. (1)


Options 0. No change compared with the current situation.(0)

Option 1. Provides a ‘better regulation’ incorporating new guidance on state-of-the

art technology. (1)


0 – Baseline -1 0 0 0 0 0 -1

1 – More guidance

on other means

different from

paper

1 1 1 1 1 1 6

4.4.7. Lack of guidance on the acceptability of new technology, such as RFID

(Radio Frequency Identification)

1. Safety impact


Option 1. The introduction of RFID (passive or active) is a change to the aircraft and,

if approved under Part-21, does not impact the safety. But the device is installed on

the component and cannot be used as the ‘primary’ source of the records to prevent

the loss of information in case of accident. (-1)



3. Social impact


4. Economic impact











0 – Baseline 0 0 0 0 0 0 0

1 – Guidance

on RFID as

records

-1 0 0 0 0 0 -1


airworthiness records

There are some differences between the FAA and EASA systems but this topic is covered

by the bilateral agreement, so no action expected by this rulemaking task.


1. Safety impact




Option 1. More paper to be kept longer, without a safety benefit. (-1)

3. Social impact


4. Economic impact


Option 1. More paper to be kept longer, without a safety benefit. (-1)






0 – Baseline 0 0 0 0 0 0 0

1 – Maintenance

records as part

of the log book

to be retained

until completely

removed from

service

0 -1 0 -1 0 0 -2





4.5. Comparison and conclusion

4.5.1. Comparison of options

The following analysis shows the qualitative summary of the previous assessment,

highlighting the option which results in more benefits.

Inconsistency in the use of the terms ‘Life Limited Parts’ and ‘Service Life Limited Parts’

Options Total score

0 - Baseline 0

1 – Clarify current terms 2

2 – Use ‘critical component’ 2

3 – Use ‘time controlled component’ and ‘life limited parts’ 5

So, option 3 provides more benefits, which is ‘The use of terms ‘time controlled

component’ and ‘life limited parts’ and clarifies records requirements depending on the

type of component’.

Different interpretations as to which components require an EASA Form 1 or equivalent,

and which documents are considered equivalent to an EASA Form 1

Options Total score

0 – Baseline 0

1 – Clarify when EASA Form 1 must be retained 3

Preferred option : Option 1 is ‘Identify when the EASA Form 1 must be retained’.

Different interpretations of the need for ‘back to birth’ traceability

Options Total score

0 – Baseline -1

1 – Introduce ‘back to birth traceability’ -2

2 – Introduce ‘in-service history’ 3

Preferred option : Option 2 is ‘Introduce the term ‘in-service history’ which partially

incorporates the concept of back to birth traceability but keeping some records up to a

certain extent defining ‘detailed maintenance records’.

Inconsistency in 145.A.55 of the record keeping periods and the periods applicable to the

transfer of records

Options Total score

0 – Baseline 0

1 – Change retain period from 3 to 2 years 1

Preferred option : Option 1 is to change the applicable period to transfer of the records

from three to two years.

Lack of guidance on the acceptability of records copies (scanned, photocopy)

Options Total score

0 – Baseline -1

1 – More guidance on other means different from paper 6

Preferred option : Option 1 is to create additional guidance to accept records others than in

‘original paper’.





Lack of guidance on the acceptability of new technology, such as RFID (Radio Frequency

Identification)

Options Total

0 – Baseline 0

1 – Guidance on RFID as records -1

Preferred option : Option 0 is no change in rules.


Options Total score

0 – Baseline 0

1 – Maintenance records as part of the log book to be

retained until completely removed from service

-2

Preferred option : Option 0 is no change in rules.


5. References



5. References

5.1. Affected regulations

Annex I to Commission Regulation (EC) No 2042/2003 (Part-M)

Annex II to Commission Regulation (EC) No 2042/2003 (Part-145)

5.2. Affected CS, AMC and GM

Annex I to Decision 2003/19/RM (AMC to Part-M)

Annex II to Decision 2003/19/RM (AMC to Part-145)

ED Decision 2012/018/R (AMC and GM to Part-CAT)

5.3. Reference documents

ICAO Annex 6 — Operation of Aircraft

Directive 1999/93/EC of the European Parliament and of the Council of 13 December 1999

on a Community framework for electronic signatures10

Study on Cross-Border Transferability (by the Aviation Working Group (AWG))

10 OJ L 13, 19.1.2000, p. 12.